Liverpool Range Wind Farm

To Director-General Department of Planning,

We are land holders within the Coolah-Cassilis area and we strongly object and protest to the erection of wind turbines by Epron (application number 10-0225) in this area.
We purchased our property 5 years ago so as we can retire and live a peaceful and relaxing lifestyle while being able to enjoy a lovely outlook.
If these wind turbines are to proceed, we as neighbouring landholders will be disadvantaged both economically and aesthetically. Research shows there are issues with noise, health and land values where wind turbines are present, which in turn affects us due to the value of our retirement and lively hood property diminishing considerably in value, not to mention the peaceful environment that we are now enjoying at present will be taken from us for good, and all because a neighbour is happy to have wind turbines.
This is not acceptable for a company to affect people's lives without any consideration to people's future, even when we strongly protest to this.
Surely there are more remote areas that will not have this negative impact to rural townships where wind turbines can be erected.
We certainly did not move and would not have moved to this area under the idea that wind turbines were going to be erected!!!!!
Thank you
Glenn and Natalie Jones

Coolah District Development Group Inc submission re the Liverpool Range Wind Farm
29th September 2014
SECTION 4.5.4 - Community Enhancement Fund
The Coolah District Development Group believes that an essential part of the conditions of consent is to establish a Community Enhancement Fund and it should be part of the DA for the Liverpool Range Wind Farm and be built into the final operating entity's corporate arrangements, with essential conditions:
* that the funds need to be expelled in the immediate impact zone
* Selection criteria that will ensure a shared benefit of the fund is distributed to not only the 21 land-holders but to the communities who are directly impacted by the development
* That the community consultative committee is given assistance and skills to assist in developing the framework or structure (based on a model that's proven) for the delivery of the fund

I support the use of alternate energy especially wind

With regard community enhancement fund.
A essential part of the approval requirements for development should include a community enhancement fund . The concept of shared benefit is an imperative part of any major project that impacts a significant area and its people.

with reference to grid connection.
the prefered connection goes through sensitive environmental areas and should be avoided.
the decision for the more appropriate connection should take into consideration future wind developments. There is scope further wind development in the area of approximately 400 wind turbines. Any decision should be made in light of this possibility. Why have three separate grid connection when one common one would be less invasive. Govt needs to look at the big picture not just the individual application

1. Poor Location of batch plant on pandora road significant concerned about negative visual impact page 63
2. SECTION 4.5.4
As a apart of the DA approval process, build in a firm obligation for the final corporate owner of the wind farm to provide resources to provide assistance, training or skills and capacity to the Community Consultative Committee to be better informed on the structure of the community enhancement fund And that the establishment of the community enhancement fund be apart of the approval process. And that the beneficiary of the enhancement funds be that of the local community of those in the impact zone.
3. That as apart of the approval process that the final WF owner be held accountable to provide the community and residents whose property involved should receive a copy of the report detailing the before, during and after benchmark research data which has been conducted for all impacts sectors on their properties; i.e.; environment, visual, auditory etc
4That as apart of the approval process that the final WF owner be held accountable to ensure the proximity of overhead power lines near homesteads have no negative impacts on the residents, visual or otherwise.

Submission: Liverpool Range WF Project
1. Road Traffic
The rural roads within the construction zone currently have low daily vehicle movements and very few heavy vehicle movements.

Most of the rural roads within the construction zone are just wide enough for two light vehicles to pass by moving slightly onto the road shoulder. To pass heavy vehicles, light vehicles usually pull over further onto road shoulder. If oncoming vehicle is very large e.g. B double, often local drivers pull over as far as possible to prevent larger truck having to pull onto road shoulder, also to prevent stone damage on their vehicle. This will be difficult for the wide and extra-long load trucks to pass cars and other trucks on the small rural roads.

The Road Traffic Management Plan to be done prior to commencement of construction the following points should be requirements:

a. A localised media campaign to be undertaken to alert the community within the construction zone, and adjacent communities, of the expected significant increase in light and heavy traffic movements.

b. Extra signage to warn travellers of large vehicle movements during construction phase.

c. Consideration of the school bus runs and the location of the pick-up and drop off points along the bus route to ensure student safety.

d. A published timetable for very large escorted trucks movements using major local roads, and minor roads to minimise local community inconvenience and impact.
e. Complaints hotline so public have a contact point to report any dangerous drivers or situations.

2. Light & Dust
The Warrumbungle Shire has Development Control Plan 1 Lighting Code to protect Siding Springs Observatory . This code should be adhered to across entire construction zone, not just in Warrumbungle Shire. Dust mitigation aids in reducing light reflecting into atmosphere.

3. A Community Enhancement Fund should be made part of a condition of consent to ensure any future owner of Wind Farm complies with community expectation to share some of the income benefits from the Wind Farm.
* The funds should be for the benefit of the host region impact area of the Wind farm (Coolah, Cassilis, and Merriwa).
* A facilitated consultation process with communities on structure and administration of Fund, the guidelines and criteria for expenditure of monies.
* Committee should include a number of local residents
* Fund should support local charities, community groups and community initiatives including skill development of groups, public infrastructure development or upgrade

4. The construction phase, workers to be domiciled where possible in local accommodation to help local economy.

5. Operation staff to reside locally where possible to maintain local community.

6. Some form of obligation for the provision of apprenticeship opportunities and/or training for regional youth.

I support the proposed wind farm for the following reasons:
* Diversification of local & regional economy
* Renewable energy development
* Diversification of income base for land host to help offset climate and commodity price impacts
* New workforce skill set in local and regional work force
* Community enhancement fund to help finance local communities initiatives
* New employment opportunities which will help retain some of the regional youth
* New business opportunities for local & regional businesses
* Landholder participation is voluntary
I am a potential land host.

I wish to object the proposal of the Liverpool Ranges Wind Farm due to the following impacts;

Noise
Visual
Health
Fire Hazzards
Flora & Fauna

Whilst this project is very ambitious, it will always come at a huge cost to the local residents, causing dreadful impacts on their life.

NSW Department planning guidelines for wind farms leave far too much room for the likes of Epuron to destroy what residents have worked hard for, and dont wish to have imposed on them.

Who will ultimately be responsible for the damage to health and property at the end of the day? Will it be the NSW Government, Epuron or the involved landowners? It should be ALL three of them. The tide will turn, and the wind industry will be turned on its head, and residents will be looking at all three parties involved to compensate them for what they have suffered and lost.

The most important factor in all of this -how can the Government keep stripping taxpayers of ludicrous amounts of money to prop up something as non viable as a wind farm? Why is there no common sense involved?

Lastly, I object wholeheartedly to what is proposed for a beautiful part of the world. This will destroy peoples lifestyles, their health and the countryside so the government can reach a fantasy target for renewable energy, that, JUST DOES NOT WORK.

I also reserve the right to submit any further information that comes to hand at a later date.

I object to the Liverpool Wind Farm, as policy and legislation needs to change, become fairer and have more substance prior to any further approval of wind farms. Because the draft guidelines are in fact only in draft form and the wind farm company has no formal requirement to adhere to them, there is a significant lack of protection for non-hosting properties forced to live near wind turbines. The constant stream of community division and community concerns that follow on with each new wind farm proposal should be a red light to the NSW Government that more needs to be done, yet every single rural community faced with a wind farm has its opinions and concerns blatantly ignored by the Government. Yet there is a feeling of deja vu with every new proposal.
The Guidelines on CCC membership are designed to bring a bit of balance to the CCC process. For instance they specify:
- five to seven representatives of the local community and other stakeholders, including at least two representatives of any landowners that own houses within 2km of a proposed wind turbine.
- one representative of the local council.
I'm sure those who drafted the guidelines didn't anticipate a wind farm spanning 5 council areas and this needs to be taken into account for the Liverpool Range venture.

What can be seen from the 2nd meeting of the Liverpool Range CCC, there is:
An independent chairperson - which by definition can't be independent as they get paid by the developer
Members from 3 different councils
2 uninvolved landowners
1 involved landowner
2 Epuron representatives.

The council representatives have a financial interest as all wind farm developments have a community enhancement fund. From this it is easy to determine that there is no balance at all. This has been the case for the whole process.
Why has the DPE allowed this to happen in the first place and still allow it to continue?

This process has shown how the meetings have been run. If one reflects on the minutes of the meetings and indeed they are a true reflection of the meeting, it confirms that the uninvolved landowners are ineffective in representing the affected community on issues such as noise, visual amenity and property devaluation.
In summary
- There has been no community consultation until after the event.
- The CCC process has not been followed.
- The developer should be told to reconstitute the CCC as per guidelines under a new independent chairperson, paid for by the department, and do some real consultation for 6 months.
- The EA should be put on hold until this has happened to the community's satisfaction.
- The department should formally investigate how it let the CCC process collapse before it is taken out of their hands.

Every action and inaction by the department seems to be to the benefit of the developers and to the detriment of the affected community. This cannot be allowed to continue.
At the PAC meeting in August to review the Gullen Range amendment, a large number of speakers said that the department and the process needs to be subject to an "inquiry", a "judicial inquiry" or in one case a "royal commission". This review of a small part of the Liverpool Range process, lends weight to that suggestion.

Further, the proposed Liverpool Range wind farm should be rejected on strategic grounds and because of fatal defects in multiple essential parts of the environmental assessment.
Either of these alone is sufficient to reject the proposal. In combination they are overwhelming grounds for rejection.
On the basis that the proposal will contribute to the rapid escalation of consumer and business electricity prices that has occurred in NSW in the last 7 years, with Sydney consumer electricity prices exploding by 121% in that period the Liverpool Range proposal would contribute to a continuing increase. Unless the department believes it is NSW Government policy to:
* raise consumer electricity prices very much faster than by depending on conventional forms of electricity generation; and
* impose the greatest hardship from this policy on the lower income segments of the NSW population then the proposal must be rejected.
In addition to that, using out-dated AEMO forecasts, the EA blatantly attempts to mislead the DPE/PAC about the timing of potential electricity shortfalls for NSW, which AEMO puts at
least a decade from now.
Therefore, there is not a supply reason to build Liverpool Range wind farm. It only serves the developer's interests in acquiring REC payments while forcing up NSW electricity prices.
So on strategic grounds the proposal must be rejected.
.

I object to any approval of this proposed wind farm development.
The reasons for my objection are:-
a) NSW cannot afford to allow the construction of this wind farm given the huge economic losses it will force onto all businesses that rely on electric power. Further it is against all principles of natural justice to force consumers of electricity to pay massive indirect subsidies that transfer their wealth to corporations and rent seeking landholders who host wind turbines;
b)NSW does not require the addition of electric power generation. Demand for electricity is falling;
c) Wind farms are not a genuine source of 'renewable power'. The electricity produced is variable, intermittent and often only available when it's not needed. As a consequence there is no reduction in GHG emissions except in theory;
d)The truth of points a,b and c are indisputable having regard to the empirical evidence that is now well documented in overseas experience;
e)current Department of Planning draft wind farm guidelines are totally inadequate to protect the health and well being of those persons forced to live within a 10 kilometre radius of wind farms. The evidence of this has been supplied to the Department and ignored both by it and the Planning Assessment Commission. Ignoring the evidence does not mean it does not exist;
f) This wind farm will destroy and cause social disharmony in the rural community into which it is forced for not one sustainable public benefit. In this time of broader national disharmony it is imperative that harmonious communities are not destroyed but fostered.

The following concerns are raised from the EA on exhibition:
A. The location of the construction sites, specifically that on Turee Vale Rd. There has been no direct communication with potentially impacted adjacent landholders to that of the proposed construction site location (Appendix E s6.4 of the EA) with increased frequency of traffic movements and subsequent potential safety risks.
1. The estimated changes to motor vehicle and heavy vehicle movements will impact the accessibility to surrounding properties and this does not appear to be acknowledged in the EA. Turee Vale Rd traverses properties, and is utilised by landholders for access across their property and for livestock movements. This has not been communicated with the potentially affected landholders.
2. Cattle ramps exist along Turee Vale Rd that are under the responsibility of the individual landholder to maintain. These cattle ramps are not of sufficient width for the proposed increased traffic, yet no communications have been made with the individual landholders on the potential impact. The only reference is Appendix E, Traffic and Transport, which references communications with local government and not individual landholders on roads in general.
3. The heavy loads and increased frequency of the vehicle movements will also impact wear and tear on roads, which includes local, state and regional roads. The logistics of carting aggregate and water from a distance of up to 150 to 200km will have significant impact on all road categories, yet there is no assurance that impacted local roads will be maintained to the same standard as state or regional roads.
4.. The proposed construction site location is sited close to residences on the same property, however residences on adjacent properties are also anticipated to be impacted with an estimated construction noise rating of up to 50dBA for residence D7-5, and no notification of this has been provided to the individual property owner. Input from surrounding landholders into the Construction noise management plan is requested, and a clearly defined complaints and resolution process with an independent third party involvement if requested.
5. Operational conditions of the proposed construction site are not clearly stated - only the location, limited descriptions of the activities (eg. concrete batching plant) and operating hours. Minimal reference to dust and impact from local environmental conditions such as inversion layers that are common to the tight valley landscape. The estimated quantity of concrete production of up to 400m3 per day is a huge number of heavy vehicle traffic movements with heavy loads, being potential dust generators from vehicle movement and the batching process.
6. Road corners/bends - there are a number of bends and corners/turns that will require amendment to enable the heavy vehicle and over-dimension vehicle movements, yet they are not all referenced in the EA, particularly on local roads in the Warrumbungle Shire. There is also no indication of how individual landholders may be compensated if the road modifications to enable these vehicle movements impacts their properties.

B. Photomontages - a request for a residential view matrix assessment be undertaken for house D7-2.

C. Radio frequency interference not considered. Concern over impact to local radio station broadcasts, local UHF and other radio transmission quality, including private radio and wifi networks in the region.

D. Bushfire management - reliance on the Rural Bushfire Brigade for bushfire management transfers responsibility back to landholders who are volunteers. No commitment evident from the wind farm proponents. The location of the existing Bushfire units are from 9 to 25km away from the construction site located on Turee Vale Rd, which may be considered an ineffective distance for quick response to fires. Volunteers are to date trained in grass and bush fires, not fires in building and equipment. Clarification is needed as to the investment by the windfarm proponent, particularly during construction, for provision of resources, bushfire management planning and availability of trained staff for bushfire response. Nearby residences to the construction site have an increased risk to fire due to the proximity to vehicle movements and construction operations, yet no Bushfire Brigade resources are proposed to be located in this proximity - relying instead on the Volunteers in the Bushfire Brigade where resources are currently located from 9 to 25km distance, and availability of volunteers is not confirmed. Please note that mobile telecommunications in the project area is extremely limited, which has significant impact to emergency bushfire response.

E. Wind turbines post construction - concern over ice forming on blades and creating a potential hazard to livestock and people. Night temperatures frequently fall below zero in winter months yet the EA states temperatures are not low enough to enable ice crystals to form, however reference to minimum and maximum temperature data conflicts with this. The nearest meteorological station is at Cassilis, or Dunedoo (60km distance from the site) and considered too far to be indicative of minimum temperatures for the project area.

F. Lights - there is no reference to the Siding Spring Observatory lighting requirements across the project area (reference Warrumbungle Shire Council LEP).

G. Community Fund - the option that a community fund is at the discretion of the proponent, together with ambiguity into the purpose of the community fund and how it is administered is concerning. Further clarification on the objectives of a community fund is required, and how it is to be administered.

Please see enclosed submission on behalf of Mark Jacobs (Yancoal Australia Ltd).

Please find my attached submission.

Liverpool Range EA submission 24 Sept 2014
My submission is an objection to the fauna work done by the proponent and their estimations of Bird Mortality. Consultants such as Brett and Biosis regularly claim bird deaths will be only one per turbine per year and they claim that magpies are the most often killed.
Recently Macarthur wind farm did published their one year bird and bat mortality report (ATTACHED), and the consultants estimated the real kill was over 10 birds per turbine per year and 30% were raptors.
The report clearly states that the wind farms programmed once-a-month searches for carcasses were inadequate, as scavenger trials found that most carcasses were removed within two weeks. The consultants recommended weekly searches, but AGL has not implemented this; I believe it is because they know they will find a massive increase in bird mortality which they would be required to act on under their planning permit conditions.
This is a common thing for wind farm companies to underestimate mortality to gain approval, then refuse to do proper searches, ensuring very few carcases are found.
Pacific Hydro commissioned Biosis to do a mortality and bird use survey at their Yambuk and Codrington wind farms. This report is available from Pacific Hydro, and states that the native bird population was reduced to 50% of its initial population in the first year of operation, and then steadily declined year on year. It was found that wind farm disturbance or mortality also diminished the native bird population by 50% FOR 5KM around the wind farm Some species such as cranes and migratory birds were completely absent.
Crane surveys at Macarthur, Waubra and Portland have shown the displacement of these birds by 5 to 6km, depending on the size of the turbines. Studies in Texas by Laura Navarrete have shown the bigger the turbine the greater the disturbance of the birds out to 14 km, with the mean at 8km..
The wind industry kills millions of birds and bats across the world every year. In Spain alone, wind farms are killing between 6,000,000 and 18,000,000 birds every year. The figures come from 136 monitoring studies collected by the Spanish
I believe the Liverpool Range proposal will pose an unacceptable risk to birdlife in the proposed area and for many kilometres around.
I also believe the proponent has not adequately addressed the bird mortality issue and should not be allowed to build the wind farm because of their misleading and inadequate work. All these reports and studies are available showing the real threat to bird life, yet this proponent chooses not to use any of them.

See uploaded submission and additional attachment.

Hi Swati
Please add this appendix to my initial submission.
Best Regards
Tony Gardner

Details provided in attached documents.

Copy of Liverpool Plains Shire Council submission is attached

Please find attached submission on behalf of Warrumbungle Shire Council

Attached is pdf document that focuses on the Community Consultative Committee process in the Liverpool Wind Farm development.

Regards
Jane Keany